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and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) t
eaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed in B. 9
nt be followed and fulfilled. Your truly, MARTIN WEINBERG, ESQ. ROY SACK, ESQ. /wg By Black. Srebnick. Kornspan & Stumpf. I'.A. EFTA00207723 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 10-80309-CIV- JANE DOE No. 103, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO
and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) t
eaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed in B. 9
nt be followed and fulfilled. Your truly, MARTIN WEINBERG, ESQ. ROY LACK, ESQ. /wg By Black. Srebnick. Kornspan & Stumpf. I'.A. EFTA00213247 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 10-80309-CIV- JANE DOE No. 103, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO
citation and quotation marks omitted). "Any doubt as to whether a motion for leave should be granted should be resolved in favor of the amendment." Santos v. Flores, 116 So. 3d 518, 520 (Fla. 3d DCA 2013). B. Standard for Punitive Damages In order to assert a claim for punitive damages, a plaintiff o
d among Epstein, the Government and Epstein's alleged victims during the plea negotiations. 9 EFTA00613417 22. On April 7, 2015, Judge Marra of the United States District Court for the Southern District of Florida confirmed, as a matter of law, the impertinence of the Joinder Motion's allegations about Dershowitz abusing
, and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos supra, at 2025: 3 See argument in sections (2) and (3) th
the individuals referred to in paragraph (7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives h
Entities connected to both Santos and the United States District Court

Jeffrey Epstein
PERSONthe Southern District
LOCATION
United States
LOCATION
Alexander Acosta
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSONJack Goldberger
PERSONLeon Black
PERSON
Alan Dershowitz
PERSONGerald Lefcourt
PERSON
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSON
Scarlett Johansson
PERSON
Virginia Giuffre
PERSON